The following revised version of 2007-17 is submitted for consideration.
The amendments are being made to address concerns expressed by staff
in the "staff assessment" of the policy proposal.
I ran these changes by staff prior to submitting them here. The changes
do address the concerns expressed by staff, but, staff may wish to
revise
their "impact" statement. Beyond this statement, I'll leave it to staff
to comment further if they wish.
Apologies for the late date on this amendment. Look forward to upcoming
changes to the IRPEP to improve this situation.
Owen
Modifications:
Extended 4.6.1 to allow ARIN to reject transactions of no
benefit
to the community. (Hopefully this closes most of the abuse
loopholes)
Renumbered 4.6.6 to 4.6.7 Annual contact required
Renumbered 4.6.5 to 4.6.6 RSA Required if new addresses received
Inserted new 4.6.5 to spell out requirement for ARIN to work
with
resource holders to specify a return timeframe in contract.
Added text to rationale to clarify overriding intent and
Policy Proposal 2007-17
Legacy Outreach and Partial Reclamation
Author: Owen DeLong
Date: 21 February 2008
Proposal type: modify
Policy term: permanent
Policy statement:
Replace section 4.6 as follows:
4.6 Amnesty and Aggregation requests
4.6.1 Intent of this policy
This policy is intended to allow the community and ARIN staff to work
together with holders of address resources in the best interests of
the community by facilitating the return of unused address space and
the aggregation of existing space in a manner which is in the best
interests of both parties.
All transactions under this policy must either create greater
aggregation (a reduction in the number of prefixes) or the return of
address space. ARIN should reject any transaction which staff judges
is not in the interests of the community.
4.6.2 No penalty for returning or aggregating
ARIN shall seek to make the return of address space as convenient and
risk-free to the returning organization as possible. An organization
with several non-contiguous blocks seeking to aggregate and return
space at the same time should be accommodated if possible. If it is
possible to expand one block, for example, to facilitate the return of
other blocks, ARIN should do th.6.3 Return should not force renumbering
An organization shall be allowed to return a partial block of any size
to ARIN. For any return greater than a /24, ARIN shall not require
that the non-returned portion of the block be renumbered unless the
returning organization wishes to do so.
4.6.4 Incentives
The Board of Trustees should consider creating incentives for
organizations to return addresses under this policy.
4.6.5 Timeframe for return
Any organization which is returning addresses under this policy shall
negotiate with ARIN an appropriate timeframe in which to return the
addresses after any new resources are received under this policy. In
the case of a simple return, the timeframe shall be immediate. In the
case where renumbering into new addresses out of existing addresses to
be returned is required, the returning organization shall sign a
contract with ARIN which stipulates a final return date not less than
6 months nor more than 18 months after the receipt of new addresses.
If an organization misses this return date, but, ARIN believes the
organization is working in good faith to complete the renumbering,
ARIN may grant a single extension of 6-12 months as staff deems
appropriate to the situation. Such an extension must be requested in
writing (email to hostmaster at arin.net) by the organization at least 15
days prior to the original expiration date.
4.6.6 RSA Required if new addresses received
Any organization which receives any additional addresses under this
policy shall be required to sign an ARIN RSA which will apply to all
new addresses issued and to any retained blocks which are expanded
under this policy.
4.6.7 Annual contact required
Any organization which participates in this policy shall be required
to sign an agreement stipulating that ARIN will attempt contact at
least once per year via the contact mechanisms registered for the
organization in whois. Should ARIN fail to make contact, after
reasonable effort the organization shall be flagged as "unreachable"
in whois. After six months in "unreachable" status, the organization
agrees that ARIN may consider all resources held by the organization
to be abandoned and reclaim such resources. Should the organization
make contact with ARIN prior to the end of the aforementioned six
month period and update their contact information appropriately, ARIN
shall remove the "unreachable" status and the annual contact cycle
shall continue as normal. If the organization pays annual fees to
ARIN, the payment of annual fees shall be considered sufficient contact.
Rationale:
Existing policy supports aggregation (4.7) and provides some amnesty
(existing 4.6) for returning blocks. However, a number of resource
holders have expressed discomfort with the current section 4.6
believing that they will be forced to return their entire address
space and renumber rather than being able to make partial returns and
retain some of their existing space.
This policy seeks to eliminate those concerns and make the return of
unused address space more desirable to the resource holders.
A very high percentage of underutilized space is in the hands of
legacy holders who currently have no benefit to joining the ARIN
process and no way to return any portion of their address space
without incurring significant disadvantage as a result.
A suggestion to the board would be to adopt benefits along the
following lines for people returning space. These benefits would
provide additional incentive for resource holders to make appropriate
returns and for legacy holders to join the ARIN process:
1. If the organization does not currently pay ARIN fees, they shall
remain fee exempt.
2. If the organization currently pays ARIN fees, their fees shall be
waived for two years for each /20 returned, with any fractional /20
resulting in a one-time single year waiver.
3. Any organization returning address space under this policy shall
continue under their existing RSA or they may choose to sign the
current RSA. For organizations which currently do not have an RSA,
they may sign the current RSA, or, they may choose to remain without
an RSA.
4. All organizations returning space under this policy shall, if they
meet other eligibility requirements and so request, obtain an
appropriate IPv6 end-user assignment or ISP allocation as applicable,
with no fees for the first 5 years. Organizations electing to receive
IPv6 allocation/assignment under this provision must sign a current
RSA and must agree that their IPv4 resources are henceforth subject to
the RSA.
The overriding intent of this policy proposal is to make it as easy as
possible for both ARIN and resource holders to "do the right thing"
with regard to excess resources or dis-aggregated (fragmented) address
blocks. It is the desire of the author that staff make any judgment
calls necessary under this policy with that ideal clearly in mind.
While the author has made a concerted effort to make the policy as
clear as possible and
as concrete as can be, the reality is that these types of transactions
must rely heavily on the judgment and expertise of the ARIN staff in
determining what is in the best interests of the community.
Timetable for implementation: Immediate
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